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Preparation of MD 715 Reports

Preparation of MD 715 Reports. Steps to Prepare the Annual Report FY 05. EEOC Briefing Slides. Title VII – Section 717. Requires each federal agency to: Make all personnel actions free from discrimination based on race, color, religion, sex or national origin

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Preparation of MD 715 Reports

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  1. Preparation of MD 715 Reports Steps to Prepare the Annual Report FY 05

  2. EEOC Briefing Slides

  3. Title VII – Section 717 • Requires each federal agency to: • Make all personnel actions free from discrimination based on race, color, religion, sex or national origin • Maintain an “affirmative program of equal employment opportunity” for all employees and applicants • Submit annual plan and/or updates to EEOC for approval

  4. Rehabilitation Act – Section 501 • Make all personnel actions free from discrimination based on disability • Maintain an “affirmative action program plan for the hiring, placement and advancement of people with disabilities” • Submit annual plan and/or updates to EEOC for approval

  5. Which Agencies are Covered? • All executive branch departments and agencies, including the U.S. Postal Service and the Postal Rate Commission

  6. What Does MD-715 Require? • Develop and maintain model EEO program • Ensure all employment decisions are free from discrimination • Examine employment policies, procedures and practices to identify and remove barriers to equal opportunity • Develop plans to correct identified barriers • Report plans and progress to EEOC

  7. Essential Elements of a Model EEO Program • Demonstrated commitment from agency leadership • Integration of EEO into the agency’s strategic mission • Management and program accountability • Proactive prevention of unlawful discrimination • Efficiency • Responsiveness and legal compliance

  8. Element One: Demonstrated Commitment From Agency Leadership • Equal employment opportunity must be: • Embraced by agency leadership • Communicated through the ranks from the top down • EEO principles must be made a fundamental part of the agency’s culture • Agency head must issue annual EEO and anti- harassment policy statements

  9. Element Two: Integration of EEO Into the Agency’s Strategic Mission • EEO Director has regular access to agency head and senior management • EEO professionals are involved in all major human resources decisions • EEO programs have sufficient resources • Managers and employees are involved in the implementation of the agency’s Title VII and Rehabilitation Act programs

  10. Element Three: Management and Program Accountability • Conduct regular internal EEO program audits • Establish procedures to prevent all forms of discrimination • Evaluate managers and supervisors on efforts to ensure equality of employment opportunity • Maintain effective reasonable accommodation procedures • Maintain clearly defined and fair personnel policies, selection and promotion procedures, evaluation procedures, rules of conduct and training systems

  11. Element Four: Proactive Prevention of Unlawful Discrimination • Conduct a self-assessment on at least an annual basis to monitor progress and identify areas where barriers may operate to exclude certain groups • Develop strategic plans to eliminate identified barriers

  12. Element Five: Efficiency • Maintain an efficient, fair and impartial complaint resolution process • Separate investigation and adjudication functions from the legal defense arm of the agency • Establish and encourage the widespread use of alternative dispute resolution (ADR) • Maintain effective data collection systems on workforce, applicant flow and complaint tracking

  13. Element Six: Responsiveness and Legal Compliance • Ensure full compliance with Title VII and Rehabilitation Act, including EEOC regulations, orders and other written instructions • Report agency program efforts and accomplishments to EEOC • Comply with final EEOC orders for corrective action and relief

  14. What is a Barrier? • A policy, procedure, practice or condition that limits employment opportunities for members of a particular race, ethnic background, gender or because of a disability • Some barriers may be easy to identify • Other barriers are embedded in the day-to-day procedures and practices of an agency and may appear neutral

  15. Process to Address Barriers • Identify where possible barriers may exist using a variety of sources • Investigate to pinpoint actual barriers and causes • Devise a plan to eliminate barriers • Assess success of plan’s implementation • Determine if plan needs to be adjusted because additional barriers remain

  16. Sources for Information to Identify Potential Barriers • Analyze workforce statistics • Review EEO complaints • Talk to EEO and human resources staff • Talk to unions and advocacy groups • Conduct surveys, focus groups and exit interviews • Review studies by outside agencies

  17. Some Employment Policies, Procedures and Practices That Should Be Examined for Barriers • Hiring • Promotions and other internal selections • Attainment of supervisory and management positions • Training opportunities and developmental opportunities • Performance incentives and awards • Disciplinary actions • Separations

  18. Plan to Eliminate Barriers • Design corrective plan to address the identified causes of barriers • Even if barrier is job-related, explore alternatives that serve the same purpose and that have less impact on a particular group of employees • Progress should be measurable and agency officials held accountable • Periodic reassessments should be done for need to adjust plan if necessary • Report plan and progress to EEOC annually

  19. Additional Barrier Analyses Under the Rehabilitation Act • Compliance with Executive Order 13164 and EEOC guidance for reasonable accommodation procedures • Compliance with Architectural Barriers Act • Accessibility of electronic and information technology required by Section 508 of the Rehabilitation Act

  20. Special Emphasis for Targeted Disabilities • MD-715 requires agencies with 1,000 or more employees to: • Establish goals for employment of individuals with targeted disabilities • Establish goals for the advancement of individuals with targeted disabilities • Show measurable progress each fiscal year

  21. What Should Agencies Be Doing Now? • Become familiar with the new directive • Re-tool data collection systems • Initiate comprehensive self-assessments • Begin planning for operational changes • Involve key managers • Integrate EEO into all human capital planning

  22. Army Instructions • MD 715 overview • EEOC guidelines officially published Oct 03 • Army part of task force to review and comment • Army met with EEOC Team and modified web instructions to address Army issues • EEOC met with Army in April 05 to evaluate Army MD 715 report submission and further modify Army reporting requirements

  23. Overview • At its core MD 715 • Cleaned up MD 714 • Not a lot of new theory • Repackaged • Uses standard occupational categories (SOC) and 9 Federal Categories • Refines and defines reports to be submitted

  24. Overview • MD 715 is the roadmap for the EEO program • Combines MDs into one document • Forces EEO to focus on metrics and continual assessment • Complaints and AEP are equally parts of EEO • Forces greater precision in reporting and barrier analysis • The census tool a superb improvement over the 1990 telephone books

  25. Overview • Requires retooling of federal HR data systems • Core data tables require new fields • Additional tables may be required • Some data elements aren’t connected • PATCOB is eliminated • Replaced by FED9 (same as EEO1)

  26. Overview • Census tool designed for private sector • Hard to find federal series • Not all federal occupational series fit neatly into SOC and fed9

  27. Main focus • Model program • Barrier identification and reductions • Self assessment • Statistical validation • Precision in data selections • Metrics

  28. Who Submits • MACOMs/IRA/OSA/FOAs submit to EEOC HQ and HQ DA • All others submit to • HQ DA • MACOM • Region/district/MSC • Don’t be surprised if EEOC spot checks and asks for a copy of your report or copy of signature page

  29. MD 714 (1987) PATCOB UR Reporting Levels Flexible formats Noteworthy accomplishments MD 715 (2003) SOC and Fed 9 Omitted (Pending) Changed Specific Forms for Program Elements Executive Summary Specific and Detailed Metrics Data tables Action items tied to data and real time requirements Comparisons

  30. Special Occupational Categories, census codes and FED9 replaced PATCOB (still in HR database, but not used for reporting to EEOC) Fed9 replaces PATCOB SOC based on occupational series FED9 and SOC is used to get the CLF Comparisons & Changes

  31. SOC or census codes Used for series CLF Census codes more precise than SOC SOC or census codes more precise than PATCOB PATCOB too vague Original crosswalk table on EEOC web site replaced by Army Crosswalk Original crosswalk had 237 series – Army has 911 series EEOC and Army re-cross walked the series and developed army based EEOC categories file Army - EEOC categories included in HQ ACPERS BOA Redesign Comparisons & Changes

  32. Fed 9 - EEO-1 EEO-1(fed9) used in place of PATCOB General summaries of workforce Based on culmination of specific occupational series EEO-1 on census web site has fed9 codes included (although the caption is “EEO-1”, it means “FED9” Census codes are more precise than SOC and are used when a series that has differentiated duties are rolled into one SOC – the census code breaks down the duties more precisely Comparisons & Changes

  33. Recent Guidance • MD 715 FAQs on EEOC web site • Army met with EEOC and obtained modifications to published guidelines • Reporting levels • Some MACOMS report to EEOC (not all) • Below MACOMs do not report to EEOC but submit reports to chain of command • This year requires only look at current year – next year begins multiyear looks • Simplified data tables

  34. Recent Guidance • EEOC met with Army HQ DA EEO Staff and HQ DA HR and HQ JAG to evaluate Army’s MD 715 submissions • HR data too inconsistent – HR recommended EEOC raise issue with DoD because DCPDS is a DOD system • HR requested that Veterans Status be added to the B tables in MD 715 – EEOC agreed • Use of forms and data tables more clearly explained • MACOM reviews pending completion of total federal submissions

  35. Recent Guidance • Cross Walk changes • Original • Only 237 series were recognized, the non recognized series would not be reported • Change • All series are now mapped to census codes • All series are reportable

  36. Recent Guidance • CLF usage • Too many locations to fit into report and more than one CLF is usual • Change • Flexibility in the selection of CLFs

  37. Recent Guidance • Data Table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior Executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Data tables modified for Army conditions

  38. Recent Guidance • Data table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Pay bands added to A and B series tables

  39. Recent Guidance • Data Table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior Executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Use the supervisory descriptions already provided in HQ ACPERS instead of the ones on the EEOC web data tables. • Supervisors have their own data table

  40. Recent Guidance • Data Table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior Executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Report each senior executive pay plan individually (ES,EH, EF etc,ST,IE etc) • SES & Executive leadership has own data table

  41. Recent Guidance • Data table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Tables modified so that CLF is inserted where appropriate • Local CLF to be used except for MACOMs or Overseas organizations • Where multiple locations are required, use the most representative CLF

  42. Recent Guidance • Data table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Tenants are to be included in all data tables, supported organizations of 100 employees or more individually, and supported organizations less than 100 are aggregated into “tenants less than 100 employees” • Outside of table A/B2 tenants are totaled into “total serviced area”

  43. Recent Guidance • Data Table A & B series • Pay bands not captured • Leadership reporting too confusing • Senior Executive reporting not specific enough • CLF omitted from some tables • Tenant reporting not specific enough • Change • Tenants are to be included in all data tables, MSC, Division, Regions - supported organizations of 1000 employees or more individually shown, and supported organizations less than 100 are aggregated into “Serviced Orgs less than 1000 employees” • Outside of table A/B2 tenants are totaled into “total serviced area”

  44. Recent Guidance • Data tables • Awards • Appraisals • Honorary awards • Promotion tables • Changes • Awards have more than one table • Awards of all types • Awards by Performance Rating • Cash v Time off Awards • Simplified data tables

  45. Recent Guidance • Data tables • Awards • Appraisals • Honorary awards • Promotion tables • Changes • Table A/B10 clarified – promotions such as “9-11-12” with legal authority N6M • Promotions of all types for employees career programs • Promotions for GS 13-SES simplified • Simplified data tables

  46. Recent Guidance • Data tables • Original format too hard to use and created too many errors, debugging sessions and versions

  47. Recent Guidance • Changes • Simplified data tables • Formatted based on census CLF table formats • Only whole numbers need to be entered – percents will auto calculate • Links from previous data already entered reduces additional input • Veterans status and appointments now required on B tables • B tables too wide to be printed normally

  48. Simplified Data Tables

  49. Recent Guidance • Forms • Army policy requires all forms to be submitted • Form E • Form F • Form G • Form H • Form I • Form J • Changes

  50. Recent Guidance • Forms • Army policy requires all forms to be submitted • Form E • Use model program elements as paragraph headings • Start with generalized mission statement • Summarize how EEO services are delivered • Summarize how data was obtained • Summarize workforce issues and changes • Include web links to organizational information to reduce report size

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